Eddington v. SGT. Det. Jeffrey Snell

Pro se Plaintiff Jason Edward Eddington filed this civil rights action on July 25, 2014, against West Manchester Township police officers Jeffrey Snell, David Bixler, and Keith Roehm.[1] Plaintiff claims that Defendants violated his federal and state constitutional rights by arresting and prosecuting him for misrepresenting contractor identifying information, deceptive business practices, and conspiracy to commit theft by deception. Specifically, Plaintiff alleges that his vehicle was illegally searched, that he was arrested without probable cause, and that the manner in which he was prosecuted violated his Fourth, Fifth, Sixth, and Fourteenth Amendment rights. Plaintiff also claims that his Pennsylvania state constitutional rights were violated, and that Defendants are liable for defamation. Plaintiff seeks damages and injunctive relief in the form of release. Presently, we are considering Defendants' motion to dismiss. (Doc. 23). For the following reasons, we will grant the motion.

II. Background

The following facts are derived from Plaintiff's amended complaint and are taken as true, as they must be when considering a motion to dismiss. Fowler v. UPMC Shadyside, 578 F.3d 203, 210 (3d Cir. 2009).[2]

On July 25, 2012, a York County citizen contacted the West Manchester Township Police Department and reported she had been the victim of a tree-trimming scam. (Doc. 24-1 at 1). Defendant Jeffrey Snell investigated this matter. (Id.). The victim alleged that, despite her refusal, three men trimmed the trees on her property. (Id. at 2). The men gave her an invoice for $5, 500 but stated that they would take $5, 000 in cash. (Id.). The victim claimed that one of the men drove her to the Sovereign Bank to withdraw the money. (Id.). Upon investigation, Defendant Snell estimated that approximately $200 worth of work was performed. (Id.).

Defendant Snell visited the bank and confirmed that the money had been withdrawn. (Doc. 24-1 at 2). Shortly after leaving the bank, Defendant Snell was contacted by the bank's assistant manager and informed that another elderly citizen was complaining about being scammed, and that the alleged scam-artist was still at the bank. (Id.). Defendant Snell, accompanied by other officers, returned to the bank and detained Plaintiff. (Id. at 3). While Plaintiff was sitting in a police vehicle, the officers conducted a warrantless search of Plaintiff's pickup truck, which was parked outside the bank. (Doc. 12, ¶ 9). Plaintiff's medical supplies, medications, wallet, cash, identification card, and sneakers were seized. ( Id., ¶ 12). The truck was towed to the West Manchester Township Police station. (Id.).

Plaintiff was taken to the police station where he was interrogated. (Doc. 12, ¶ 11). After approximately 30 minutes of questioning, Plaintiff asked if he should retain an attorney. (Id.). Defendant Snell then told Plaintiff he was under arrest and read him his Miranda rights. (Id.).

At some point that same evening, Defendant Snell applied for and obtained a warrant to search Plaintiff's truck. ( Id., ¶¶ 12-13). Plaintiff tested the sufficiency of this warrant by filing a suppression motion. (Doc. 24-3). The motion was denied. (Doc. 24-4). Prior to trial, Defendants released Plaintiff's picture and articles about the case to local newspapers and news stations. (Doc. 12, ¶ 16). On September 5, 2014, Plaintiff was convicted of misrepresenting/concealing contractor identifying information, deceptive business practices, and conspiracy to commit theft by deception. (Doc. 24-2 at 20). Presently, Plaintiff is awaiting the results of an appeal. (See Comm. of PA v. Eddington, 2065 MDA 2014 (Pa. Super. Ct.). None of the items seized from Plaintiff during the criminal investigation have been returned. (Doc. 12, ¶ 15).

III. Discussion

A. Standard of Review

Rule 12(b)(6) authorizes dismissal of a complaint for "failure to state a claim upon which relief can be granted." Under Rule 12(b)(6), we must "accept all factual allegations as true, construe the complaint in the light most favorable to the plaintiff, and determine whether, under any reasonable reading of the complaint, the plaintiff may be entitled to relief." Fowler v. UPMC Shadyside, 578 F.3d 203, 210 (3d Cir. 2009) (quoting Phillips v. County of Allegheny, 515 F.3d 224, 231 (3d Cir. 2008)). While a complaint need only contain "a short and plain statement of the claim, " FED. R. CIV. P. 8(a)(2), and detailed factual allegations are not required, Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555, (2007), a complaint must plead "enough facts to state a claim to relief that is plausible on its face." Id. at 570. "The plausibility standard is not akin to a probability requirement, ' but it asks for more than a sheer possibility that a defendant has acted unlawfully." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 556). "[L]abels and conclusions" are not enough, and a court is "not bound to accept as true a legal conclusion couched as a factual allegation.'" Twombly, 550 U.S. at 555 (quoted case omitted).

In resolving a motion to dismiss, we thus "conduct a two-part analysis." Fowler, supra, 578 F.3d at 210. First, we separate the factual elements from the legal elements and disregard the legal conclusions. Id. at 210-11. Second, we "determine whether the facts alleged in the complaint are sufficient to show that ...

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